Providing Telehealth: Policies and Billing
Telehealth billing and policy requirements can vary by state, payer, provider type, service, and setting. PulseTRC helps providers across Kansas, Missouri, and Oklahoma find practical guidance for planning, delivering, documenting, and billing telehealth services. This includes reviewing state requirements, professional board guidance, consent rules, secure technology, workflow design, coding rules, place of service, modifiers, and documentation expectations. Choose your state-specific guidance below, or continue down the page for federal guidance and Medicare policies.
Telehealth State Guidance
Track telehealth legislation, regulations, and policy updates across Kansas, Missouri, and Oklahoma.
Stay up to date on pending and passed telehealth legislation across the PulseTRC region. This tracker can help providers, clinics, and community partners monitor policy changes that may affect telehealth planning, billing, and service delivery.
View Legislation TrackerGeneral Federal Guidelines
On Telehealth Policies & Billing
1. Legal and Regulatory Requirements
Standard of Care: Telehealth services must adhere to the same standard of care as in-person services.
Provider-Patient Relationship: A valid provider-patient relationship must be established prior to treatment. This can be done via:
- An in-person encounter with a physical examination.
- A consultation with a state-licensed professional who has an established relationship with the patient.
- A real-time, interactive telemedicine encounter using technology sufficient for diagnosis, if an in-person exam is not required by the standard of care. Questionnaires or telephone-only evaluations are not sufficient to establish this relationship for the purpose of prescribing medication.
Informed Consent: While not explicitly required by law for all private payer services, it is highly recommended to obtain and document patient consent for telehealth services, especially for state Medicaid participants.
Prescribing: Prescribing controlled substances via telehealth generally requires an in-person exam first, however a federal waiver is allowing prescribing of controlled substances via telehealth without a prior in-person visit or meeting one of the existing statutory exceptions through December 31, 2026.
Cross-State Services: In most cases, providers must be part of a licensure compact to perform telehealth with a patient who is physically in a different state. A licensure compact is an agreement between states to recognize each others’ professional licenses as valid. See the table above for the list of licensure compacts each state is a part of.
Interstate Medical Licensure Compact
2. Technology and Infrastructure
HIPAA Compliance: Use a secure, reliable, and HIPAA-compliant telehealth platform. Ensure Business Associate Agreements (BAAs) are in place with all vendors handling protected health information (PHI).
Required Technology: Telehealth requires the use of a two-way interactive video technology. Asynchronous (store-and-forward) technology may be covered by your state’s Medicaid program for specific specialties (e.g., dermatology, ophthalmology, radiology), but real-time video is the standard for most services.
3. Prescribing
Prescribing controlled substances via telehealth generally requires an in-person exam first, however a DEA federal waiver is allowing prescribing of controlled substances via telehealth without a prior in-person visit or meeting one of the existing statutory exceptions through December 31, 2026.
At the bottom of the page, have a visual outline of each state that users can click to link to state-specific regulatory and billing policies.
4. Ensure Proper Documentation
- Record locations and time spent in the encounter
- Details of Medical decision-making
- The platform of telehealth use
- Record of patient consent in telehealth
Medicare
Telehealth Policies & Billing
If you are a Medicare provider, there are many virtual care options available for you and your patients.
During COVID-19, the Centers for Medicare & Medicaid Services (CMS) enacted a waiver broadening access to Medicare telehealth services so beneficiaries could receive a wider range of services without traveling to a healthcare facility. The Medicare telemedicine waiver has been extended through December 31, 2027.
Virtual Services for Medicare Patients
Medicare Telehealth Visits
Providers must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home. Distant site practitioners may include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals, subject to state law.
Virtual Check-Ins
Medicare pays for brief communication technology-based services when established patients communicate with their physician or certain practitioners to avoid unnecessary trips to the office. The communication cannot be related to a medical visit within the previous 7 days or lead to a medical visit within the next 24 hours or soonest available appointment. Patient verbal consent is required.
E-Visits
Established Medicare patients may use online patient portals for non-face-to-face, patient-initiated communication with their providers. These services may be billed using CPT codes 99421–99423 and HCPCS codes G2061–G2063, as applicable.
Coding
For a full list of serviceable codes, reference the CMS telehealth services list. Bill each code with the appropriate place of service and modifier guidance.
Modifier 95
Use modifier 95 for outpatient therapy services provided via telehealth by qualified physical therapists, occupational therapists, or speech-language pathologists employed by hospitals.
POS 02
Telehealth provided other than in a patient’s home.
POS 10
Telehealth provided in a patient’s home or private residence.
Q3014
HCPCS code Q3014 describes the Medicare telehealth originating site facility fee. Bill your MAC for the separately billable Part B originating site facility fee.
FQHCs and RHCs: Refer to CMS guidance for billing Medicare as a safety-net provider.
CY 2026 Fee Schedule Highlights
G2025 continues through December 31, 2027
Non-behavioral health visits furnished through telecommunications technology may continue to be reported with HCPCS code G2025, including audio-only services.
RHC/FQHC mental health in-person requirement delayed
The in-person mental health visit requirement will not take effect until after January 1, 2028. The CY 2026 payment rate for G2025 is $97.53.
New Medicare telehealth services
- Multiple family group psychotherapy
CPT 90849 - Group behavioral counseling for obesity
HCPCS G0473 - Infectious disease add-on
HCPCS G0545 - Auditory integrated sound processor
CPT 92622 & 92623
E-Visit Codes
| 99421 | Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 5-10 minutes |
| 99422 | Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 11-20 minutes |
| 99423 | Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 21 or more minutes |
Virtual Check-In Codes
| G2010 | Remote evaluation of recorded video or images submitted by an established patient (e.g., store and forward), including interpretation and follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment |
| 98016 | Brief communication technology-based service (CTBS), e.g. virtual check-in, by a physician or other QHP who can report E/M services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion. |
| G2252 | Brief CTBS, e.g., virtual check-in, by a physician or other QHP who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion. |
Specialty Medicare Services
Medicare's Behavioral Health Integration Program
Medicare’s Behavioral Health Integration Program provides several Digital Mental Health Treatment options (see page 15 of the official guide)
| G0552 | Supply of a digital mental health treatment device and initial education and onboarding, per course of treatment that augments a behavioral therapy plan |
| G0553 | First 20 minutes of monthly treatment management services directly related to the patient’s therapeutic use of the digital mental health treatment (DMHT) device that augments a behavioral therapy plan, physician/other qualified health care professional time reviewing information related to the use of the DMHT device, including patient observations and patient specific inputs in a calendar month and requiring |
| G0554 | Each additional 20 minutes of monthly treatment management services directly related to the patient’s therapeutic use of the digital mental health treatment (DMHT) device that augments a behavioral therapy plan, physician/other qualified health care professional time reviewing data generated from the DMHT device from patient observations and patient specific inputs in a calendar month and requiring at least one interactive communication with the patient/caregiver during the calendar month |
Medicare Home Health
Home Health
| G0320 | Home health services furnished using synchronous telemedicine rendered via real-time two-way audio and video telecommunications system |
| G0321 | Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system |
| G0322 | The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (i.e., remote patient monitoring) |
For official guidance regarding Medicare telehealth services, refer to the following resources.
Interstate Practice
For a provider to offer telehealth care to a patient who is physically located in another state, the provider generally must be licensed in the patient’s state or participate through a relevant interstate licensure compact when available.
Updated June 22, 2026
